Preface T he absolute prohibition of torture and inhuman or degrading treatment or punishment1 clearly places a legal obligation upon member states to combat impunity where it is breached. Contemporary concerns surrounding impunity have been based on many recent complaints received by international human rights mechanisms citing failures by states to properly hold to account the perpetrators of ill-treatment. The European Court of Human Rights (“the Court”), for example, continues to make a considerable number of adverse judgments in this area, despite its clear elaboration of the relevant standards over many years. Thus, by the beginning of 2013, in addition to 1284 substantive breaches of Article 3 of the European Convention on Human Rights (“ECHR”)2, there were 452 findings of violation in respect of the procedural aspect of the same Article imposing the requirement for states to effectively investigate allegations and other indications of serious ill-treatment.3 The problem has also been highlighted by the Council of Europe’s Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (“CPT”), particularly in its 14th General Report4 and in many of its visit reports. 1. Hereinafter collectively referred to as “ill-treatment”. 2. Article 3 ECHR prohibits torture and inhuman and degrading treatment. 3. Violations by Article and by respondent State (1959-2012), available on echr.coe.int/ Documents/Stats_violation_1959_2012_ENG.pdf, accessed on 18.12.2012. 4. See its section entitled ‘Combating Impunity’. ► Page 5